Pennsylvania’s Non-Domiciled CDL Program is Changing: What Happened, What Comes Next, and What Carriers Should Expect

Pennsylvania’s entire non-domiciled CDL system is heading for a major overhaul that is being pushed by federal pressure, public safety concerns, and politics. Here’s what you need to know to stay compliant.

Pennsylvania’s non-domiciled CDL (NDCDL) program is now at the center of a high-stakes federal compliance showdown with major implications for drivers, carriers, and the state’s CDL licensing infrastructure.

After a series of federal audits, recent emergency rulemakings, and the arrest of a Pennsylvania-issued non-domiciled CDL holder with alleged terror-related ties, the U.S. Department of Transportation (DOT) has threatened to withhold up to $75 million in federal highway funding unless Pennsylvania fixes multiple failures in its CDL issuance process.

PennDOT has already paused all non-domiciled CDL and CLP issuance, but the story is far from over.

This article breaks down:

• What triggered the renewed scrutiny
• What corrective actions the federal government is demanding
• What changes are likely to come to Pennsylvania’s CDL program
• What the state will examine internally
• How long could implementation realistically take

What Triggered the Federal Crackdown?

1. FMCSA’s 2025 Annual Program Review (APR)

During the 2025 APR, FMCSA sampled 150 Pennsylvania NDCDL records and found:

• Two licenses issued with expiration dates beyond the driver’s lawful presence.
• Four cases where PennDOT could not provide proof that lawful-presence documents were verified.
• Two cases where lawful permanent residents were incorrectly issued NDCDLs (they should receive standard CDLs).

FMCSA said these errors revealed “procedural and programming deficiencies” in PennDOT’s CDL system.

2. Arrest of a Pennsylvania CDL Holder

A 31-year-old Uzbek national, holding a valid PA non-domiciled CDL, was arrested in Kansas and described by DHS as “wanted in his origin country” for terror-related affiliations.

Although the individual reportedly had valid federal work authorization at issuance, the case ignited political and regulatory scrutiny around verification practices.

3. Executive Order 14286

Presidentially directed audits in 2025 required FMCSA to analyze all state NDCDL activity.
Pennsylvania became one of six states identified as out of compliance.

What the Federal Government Is Requiring Pennsylvania to Do

DOT and FMCSA issued an unusually strict set of 8 mandatory corrective actions, including:

1. Immediate pause of all NDCDL issuance (already done).
2. Identify all noncompliant NDCDLs still active (over 12,000 exist).
3. Conduct a full internal audit of system flaws, employee training issues, and procedural errors.
4. Review all supporting documentation for every NDCDL transaction.
5. Report findings to FMCSA and quantify all noncompliant licenses.
6. Correct all deficiencies found during the audit.
7. Void, rescind, and reissue all noncompliant NDCDLs.
8. Resume issuance only after FMCSA approval of the corrective action plan.

The threat: Lose up to $75M in federal funding if requirements are not met.

What Changes May Be Coming to Pennsylvania’s CDL System?

Based on the findings and comparing Pennsylvania to California’s earlier enforcement actions, the likely changes include:

1. Stronger Lawful-Presence Verification Requirements

Expect:

• Mandatory retention of scanned immigration documents
• Double-verification against DHS/SAVE
• Automated date checks to prevent expiration of mismatches
• Immediate rejection of incomplete records

FMCSA signaled that PennDOT’s system currently cannot document which credentials employees reviewed. This will have to change.

2. System Upgrades to Prevent Human Error

FMCSA pointed out typographical errors that allowed mismatched expiration dates. PennDOT will likely implement:

• Automated “lawful presence expiration = CDL expiration” syncing
• Mandatory data-field validation
• Hard system blocks preventing issuance beyond verified federal dates
• Required supervisor approvals for NDCDL transactions

3. New Employee Training and Certification Requirements

PennDOT must address:

• Inconsistent document review
• Lack of standardized verification
• No record of which immigration credentials were used

Expect mandatory training, annual recertification, and new digital audit trails.

4. Expanded Auditing and Oversight

Pennsylvania will likely implement recurring internal audits similar to the annual CDL program reviews FMCSA conducts.

Possible measures:

• Quarterly NDCDL audits
• Random record sampling
• Automated reporting dashboards
• New oversight roles within PennDOT

5. Potential Re-Verification of Existing Non-Domiciled CDL Holders

PennDOT may need to contact thousands of active NDCDL holders to:

• Re-upload documents
• Update immigration records
• Adjust CDL expiration dates
• Potentially reissue credentials

California was forced to revoke or reissue more than 17,000 non-domiciled CDLs under similar enforcement actions.

Pennsylvania may face a comparable burden.

How Long Will It Take Pennsylvania to Implement Changes?

While timelines depend on audit findings and FMCSA approval, a realistic estimate:

Immediate (0-30 days)

• Full issuance pause (already done)
• Initial internal audit
• Identification of noncompliant NDCDLs

Short Term (30-120 days)

• Drafting corrective action plan
• System programming for expiration-date validation
• Employee retraining
• Re-verification of a portion of NDCDL holders
• FMCSA review cycles

Medium Term (4-12 months)

• Full system overhaul (database fields, document retention, automation)
• Completion of reissuance or downgrades for thousands of licenses
• Permanent oversight and audit processes

Long Term (12-18 months)

• FMCSA final approval
• Resumption of NDCDL issuance
• Recurring compliance audits

Important: California’s similar corrective process (triggered in 2024-2025) took nearly a full year before FMCSA allowed partial resumption.

Pennsylvania may experience a similar timeline.

What This Means for Carriers and Drivers

Until further notice:

• No new non-domiciled CLPs/CDLs can be issued in Pennsylvania.
• Transfers, renewals, and upgrades are also paused.
• Drivers with existing NDCDLs may soon be contacted by PennDOT for re-verification.
• Some licenses may be downgraded, voided, or reissued.

Carriers hiring non-citizen drivers should:

• Anticipate delays in licensing
• Review immigration document expiration dates carefully
• Ensure drivers remain compliant if PennDOT adjusts CDL expiration dates
• Consider obtaining interim training through states not under a pause

How CNS Can Help

At Compliance Navigation Specialists (CNS), we understand that managing employment verification, driver qualification files, and DOT compliance can be overwhelming, especially for growing fleets.

By partnering with CNS, fleets can significantly reduce the administrative burden of managing driver qualification files, allowing you to focus more on operations and less on compliance concerns.

Here’s how:

• Electronic File Storage: CNS securely stores all your driver qualification files electronically, reducing the clutter and inefficiency of paper-based systems.
• Automated Reminders: Receive automated notifications for expiring documents such as medical certificates, CDLs, and MVRs, ensuring timely renewals.
• Easy Access and Organization: CNS provides a centralized platform where you can easily access and organize all driver records, making internal audits straightforward and efficient.
• Compliance Expertise: With CNS’s expertise in DOT regulations, you can trust that your DQ files are maintained accurately and up to date with the latest compliance requirements.
• Scalable Solutions: Whether you manage a small fleet or a large multi-state operation, CNS’s services scale to meet your specific needs, providing tailored support to keep your fleet audit ready.

Learn more about CNS’s Driver File Management Service here.

For more information, contact us at 888.260.9448 or info@cnsprotects.com.